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Appendix H: Public Comment 4

Comment Number: FNS-2022-0015-1357-0004
All Sections: 4.3, 5.2.10.1.1
Classification: Substantive
Commenter Type: WIC EBT Processors
Organization: Forage
Excerpt Text: To further accelerate enabling WIC online for retailers, USDA could consider a new
certification and authorization process for vendors. For online platforms, for instance, a platform
that has received USDA and WIC State Agency authorization for one of its merchants can bring WIC
online acceptance to all of its merchants, immediately enabling retailers to begin transactions. This
heavily reduces administrative costs (for State Agencies to individually approve merchants), and
significantly increases access to WIC online for recipients nationwide. For merchants (i.e., “Internet
Vendors” and “Online Only Vendors”) with a franchisee model, this proposal would also help them
more easily launch WIC online and serve more recipients.
- Retailers would still be accountable to the USDA under this new authorization framework (i.e.,
certifying compliance with federal requirements and laws).
- Creating a certification for online platforms to assist retailers with online transactions will not only
expedite the process but is also consistent with the statutory independence granted to WIC state
agencies.
- As with all other WIC certifications, WIC state agencies would maintain responsibility for setting
criteria and certifying online enablement platforms within the framework of federal law and
regulations.
- WIC state agencies would also retain oversight to ensure programmatic integrity and prevent
waste, fraud, and abuse.
We further suggest that USDA consider waiving any duplicative online configuration and testing
requirements for previously approved enablement platforms. This would allow retailers to accept
WIC transactions online more quickly, by reducing the administrative burden on WIC state
agencies.
The ultimate goal should be to not only accelerate online grocery shopping capabilities for WIC
participants as quickly as possible, but also ensure the integrity of the program. In the section
below, we go into more detail on the latter portion.